According to the settlement agreement, from June 2004 to April 2005, Aqua-Loop exported items subject to EAR from the U.S. to Iran, via the United Arab Emirates (UAE), without the required authorization from the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC).

Specifically, Aqua-Loop searched for and obtained items from U.S. distributors and then exported them to an Iranian customer and co-conspirator, Parto Abgardan Cooling Towers Co. (Parto). On one occasion, Parto asked Aqua-Loop to purchase a filament winding machine in the U.S. on its behalf and forward it on to Dubai and then to Iran.

According to the settlement agreement, Aqua-Loop was assessed a civil penalty of $100, 000 that was suspended for 10 years. The company is also prohibited from dealing in any transaction that is subject to the EAR for ten years